US state money-transmitter licensing tracker
money-transmitter-licensing-trackerDomain: paymentsType: processDescription
US money-transmitter licensing is the state-by-state regulatory regime that catches platforms moving customer funds (peer-to-peer transfers, marketplace escrow with payout discretion, prepaid balances above the closed-loop threshold, certain crypto-on-and-off-ramps) and that has no federal preemption mechanism. There are 49 state regimes plus DC and Puerto Rico, each with its own definition of money transmission, its own licensing application, its own surety-bond requirement (typically 25,000 to 1,000,000 USD depending on transaction volume and state), its own net-worth and permissible-investments rules, and its own examination cadence. The Conference of State Bank Supervisors maintains the Nationwide Multistate Licensing System (NMLS) which standardizes the application UI but not the substantive obligations. The operational shape: identify the states where the activity meets the local definition of money transmission (the threshold is fact-specific, with California's MTL definition among the broadest and Montana having no MTL regime at all), pursue licensure, maintain the bonding and net-worth requirements, file per-state reports, and respond to examinations. The piece that surprises operators is the time and capital cost of a multi-state rollout: 18 to 36 months and several million USD in bonding capital is typical for a national footprint, which is why most platforms phase the geography rather than launching with full coverage.
Applicability
Applies when: markets include US AND sector is fintech.
Required by (2 regulations)
- US MTL
Per-state MTL framework + federal MSB registration; CSBS NMLS aggregator; per-state capital ($50K-$1M+), surety bonds ($25K-$7M+), examination cycles 12-36 months; NY DFS BitLicense + California DFAL substantive overlays for virtual-currency activities.
Bank Secrecy Act, 31 U.S.C. §§5311-5336; 31 CFR Chapter X; per-state Money Transmitter Acts
- UK FCA Payments
UK Authorised PI vs Small PI distinction; SPI registration under £3M average monthly volume cap; Authorised PI capital scaled to service category (€20K/€50K/€125K initial); FCA Connect platform application; ~6-12 month application timeline.
Payment Services Regulations 2017 (SI 2017/752); Electronic Money Regulations 2011 (SI 2011/99); FCA Handbook
Fulfilled by (1)
- In-house build · high effort
ClearLaunch does not accept payment from vendors. Methodology.
Evidence formats
- per-state license register
- NMLS filings
- surety bond certificates